Kenya: Virtual Asset Service Providers Act, 2025 (Act No. 20 of 2025) including prohibition of goods and services entered into force with grace period

On 4 November 2025, the Virtual Asset Service Providers Act 2025 (Act No. 20 of 2025) including prohibition of mixer and tumbler services enters into force with one-year grace period for existing providers. Under section 21(1)(a) of the Act, all virtual asset service providers are prohibited from undertaking mixer or tumbler services or anonymity-enhancing services in or from Kenya. The Act defines mixer or tumbler services as cryptographic facilities or services that mix different streams of potentially traceable virtual assets, concealing the origin of funds of a particular virtual asset. Anonymity-enhancing services are defined as offering, facilitating or executing transactions in digital assets with the effect or intention of concealing information. A person who contravenes this prohibition commits a criminal offence and is liable, upon conviction, to a fine not exceeding KES 10 million or imprisonment for a term not exceeding 5 years, or both, in the case of an individual, and to a fine not exceeding KES 25 million in the case of a company.